We do business the right way

We act in the best interests of Nokia and use Nokia information, property and resources primarily for Nokia’s benefit and to support Nokia’s business needs.

Nokia employees must fully and promptly disclose all personal interests that might reasonably be perceived as affecting our judgment to perform our roles at Nokia or that may create an appearance of impropriety.

We avoid any activity at work or outside of work that might interfere with our obligations to Nokia or that could hurt the good reputation of Nokia.

• Financial or other interests and positions in companies that you could use to influence Nokia’s current or future business regarding those companies and their customers, consultants, or suppliers.
• Decisions where the potentially affected parties have close personal or family relationships with you, or where you or your family might stand to benefit in a personal capacity.
• Recruiting, hiring, or supervising family members or close personal friends, or promoting someone with whom you have such a relationship.
• Performing outside work during Nokia business hours or using Nokia’s resources, intellectual property, or confidential information for non- Nokia-related work.
• Serving as an officer or director of a charitable or civic organization that may obtain, or seek to obtain, funding or support from Nokia.

• A conflict of interest exists where you as an employee have a personal interest that can influence or interfere with your obligations to Nokia. A conflict can be actual, potential, or perceived.
• The mere appearance of a conflict can have negative effects, including damage to reputation, loss of trust, and damage to morale. It is important to consider how your actions might appear and to avoid the perception of a conflict of interest.
• Having a conflict of interest, in and of itself, may not constitute wrongdoing. A conflict of interest may exist even without improper conduct, but it must be promptly disclosed and properly managed. A conflict of interest that is not promptly and fully disclosed and/or properly managed can become problematic and may cause others to question your integrity and loyalty to Nokia.

Nokia engages with international bodies, governments, government officials and political stakeholders at multiple levels and in a variety of ways, including:

• As a business providing goods and services;
• As a concerned corporate citizen petitioning to protect our interests;
• As a taxpayer;
• As a private sector participant providing jobs and economic opportunities in many countries around the world.

Nokia is committed to a transparent and honest dialogue with government officials and political stakeholders. When interacting with government officials we are honest, truthful, accurate, and we follow Nokia’s policies  and any applicable laws. Special requirements apply to our interactions with government customers and state-owned enterprises, including, for example, rules relating to procurement, lobbying, entertainment, hospitality, disclosure, and record-keeping.

• Government officials requesting information from Nokia: Verify that the officials have a right to such information in conformity with the law and that Nokia has a right to deliver such information. When applicable, follow the relevant procedure or seek guidance from Legal and Compliance.
• Public procurement rules: Do not deviate from a government’s public procurement or tender process, even when a government official may indicate that such a deviation is acceptable or condoned.
• Be aware that recruiting a government official or member of the official’s family for employment at Nokia while the official is in a position to influence Nokia’s business with the government may lead to perception of conflict of interest and may violate applicable laws and regulations. You also need to conform to the rules of the institutions they previously served. 
• Offering gifts or hospitality to government officials when the gifts or hospitality do not comply with applicable law, including local rules and regulations, as well as established Nokia thresholds and approval requirements for corporate hospitality. This includes benefits offered via third parties. 
• Any activity that might be perceived as an undue attempt to influence the behavior or decision of a governmental official.  

• “Government Official” refers to any individual who holds a political office, as well as any individual who is an employee, representative, agent, officer, or director of any government body or agency, (at any level of government for example, local, state, provincial, federal,) or of an international organization, such as the World Bank. A Government Official also includes any employee, representative, agent, officer, or director of a “state-owned enterprise” (SOE), meaning any company that is majority owned by a government entity, or otherwise controlled or managed by a government entity. Be aware that countries differ in their governance principles, structure and official titles.
• Nokia is independent of any political affiliations. Nokia’s policy does not permit participating in the political or electoral process through donations to political groups, but Nokia does protect its interests through lawful and transparent advocacy with governments and law makers.
• Your personal political activities must be conducted on your own time and with your own resources, and in no way involve or be perceived to involve Nokia. Personal political activities include for instance supporting or advocating legislation or supporting and donating to candidates for office.
• Nokia employees should contact the Nokia Policy and Government Affairs (PGA) team when planning to engage with a government official for advocacy purposes.

Nokia competes fiercely but fairly.

Competition (or antitrust) laws regulate the activities of companies to ensure fair competition for the benefit of consumers and other market participants.

These laws prohibit business alignment or sensitive information exchange between competitors. They forbid exclusive or other business-restrictive arrangements with customers, suppliers, or trade partners unless strictly necessary to a legitimate project and market impact is limited. They prohibit unfair behavior by market-powerful companies. 

Compliance with competition laws is essential to Nokia’s business strategy.

• Nokia competes with many more companies than its main competitors.  Customers, suppliers, or trade partners may also be competitors in other contexts.
• Even informal discussions or passive involvement in a conversation may amount to a competition violation. If caught in problematic conduct, immediately object. If the conduct continues, leave the discussion.  Always make sure all your objection steps are on record.
• Nokia may enjoy a position of market strength in narrow segments, territories, or for given customer opportunities. If so, Nokia must behave fairly with all parties. 
• Take care with language in all documentation and communications, including emails and instant messages on work or private devices, to avoid expressions being misinterpreted as implying unfair practices. 
• For any meetings with competitors, create an agenda and take care that discussions do not stray into business alignment or sensitive information sharing on competition parameters.

• It is illegal to align or share sensitive information on any competition parameter with competitors (e.g., prices and other key commercial terms, granular financial information (such as costs or margins), confidential product specifications or KPIs, sales volumes, ongoing market activities or commercial plans, innovation or product development plans, procurement or employment strategies or terms.)  
• It is illegal to divide up markets, customers, suppliers, tenders, or employees among competitors, to dictate resale prices, to engage in collective boycotts or to denigrate other companies through inaccurate or exaggerated statements. 
• It is illegal for market-powerful companies to act unfairly and try to exclude or exploit other parties, including through exclusive dealings or incentives (e.g., exclusivity rebates or rights of last call), discrimination, self-preferencing across markets, unfair pricing (too high or too low/below costs), forced product tying, refusal to supply essential inputs under fair terms, or artificially raising market entry or expansion obstacles.
• Exclusive or other business-restrictive arrangements with customers, suppliers, or partners, bidding consortia or multiple bidding, as well as legitimate cooperation with competitors requires consultation with our Legal and Compliance team.

Nokia employees - you can find more information on this topic HERE.

Nokia wins its business on merit. We will not tolerate improper or corrupt payments, including bribes or kickbacks, made directly or indirectly to or from a customer, government official, or third party, including:

• Improper gifts;
• Entertainment, gratuities, donations;
• Favors such as advantageous contract terms, selection for jobs, or ignoring normal procedures;
• Any other inappropriate transfer of value.

Facilitation payments (sometimes referred to as “grease payments”) are likewise prohibited. We will engage only reputable third parties who share our commitment to integrity.

Nokia is committed to complying with all applicable financial record-keeping and reporting requirements and all applicable anti-money laundering laws and regulations, as well as laws and regulations prohibiting terrorist financing and the facilitation of tax evasion and fraud. Nokia conducts business only with third parties involved in legitimate business activities with funds derived from legitimate sources.

• Unusual, excessive, and out of the ordinary requests for travel, lodging, hospitality, or any other benefit for government officials, customers, or their family members or friends.
• Requests for donations to charities or organizations that may be affiliated with a government official or a customer.
• Service providers that suggest unusually “fast” clearance of goods through customs, visas or work permits through immigration, or issuance of government permits.
• Requests to record a transaction inaccurately or incompletely or to expedite approval or payment in a way that might compromise financial controls.
• Receipt and approval of false or inflated invoices from a supplier or providing a competitive discount that is not justified and documented. These situations may create excess funds that could be used for kickbacks or bribery.
• Requests to provide payment to a third party that is not the entity with which we are doing business, or through an offshore account.

• An improper payment involves the receipt or transfer of anything of value to the recipient (not only cash, but also any other benefit, hospitality, or service) that is unlawful under applicable law or not permitted by the recipient’s rules or Nokia’s policies and procedures.
• Exercise prudence and caution when interacting with government officials, which can include employees of a customer that is a state-owned or controlled enterprise.
• Never give – or authorize a third party to give – a gratuity or payment to a government official to expedite a service, such as customs or immigration clearances, permits, or issuance of licenses or approvals.
• Improper payments can expose Nokia and you personally to criminal prosecution. Always seek advice if you are uncertain about the legitimacy of any payments or the purpose thereof.

Nokia employees - you can find more information on this topic HERE.

The provision of items, including but not limited to hardware, software, documentation, source code, technical data, or other technology around the world, is regulated by national and international trade and sanctions laws that may impact Nokia’s operations in multiple ways.

The physical or electronic transmission (in paper format, by email, or through the Internet or other electronic means) of items across borders, or even the written or oral exchange of information among citizens of different countries who are all co-located in one country, are in scope of these laws and may be strictly regulated.

Nokia is committed to compliance with all applicable trade laws and regulations that impact its operations, including export control, sanctions, anti-boycott, and customs compliance. We are committed to preparing, executing and reporting international business accurately and transparently to trade authorities.

• Manual shipments (outside of company ERP systems), items in luggage carried on business trips, and any controlled technology transmitted by email, server access, orally or other means.
• Payments to a customs broker that exceed the invoice or are for suspicious or unidentified services; any inaccurate description, classification, or valuation of goods or data on invoices, customs forms, and other related documentation.
• Companies or persons we think might attempt to evade applicable trade laws to a prohibited destination via trans-shipments.
• Unclear, vague, or incomplete answers from customers or third parties about the end use/end user, delivery dates, and locations.
• Personal export shipments must not be done using company resources or processes.

• All Nokia employees must consider and apply the applicable trade rules when arranging any cross-border transactions, including financial transactions, technology transfers, transactions that are free of charge, returns, or hand-carried goods.
• All exports and imports must be declared accurately with correct documentation, country of origin, tariff classification and value. Import and export documentation must be systematically archived for audit purposes.
• Exports are not just the physical transfer of goods, but include the release of technical information in paper format, via electronic means, or orally through exchanges with others.
• Carrying electronic devices that contain controlled information across borders is considered an export that may require an authorization; this includes information held on electronic devices.
• Many countries impose restrictions on the transfer of certain technologies and data. Some countries completely forbid business with certain other countries. Export restrictions and sanctions may apply.